Laurelhurst Community Club

Laurelhurst Community Club

Serving 2800 Households and Businesses in Seattle’s Laurelhurst Neighborhood

Public Hearing on the Draft EIS for Children’s Hospital

July 10, 2008

The Laurelhurst Community Club (LCC) supports the mission of Children’s Hospital, its important work and reasonable expansion consistent with the City’s Comprehensive Plan and Land Use Code. LCC offers the following preliminary comments on the Children’s Draft Environmental Statement (DEIS).

Public Benefit/Bed Projections

(Statement by Jeannie Hale)

The Major Institutions Code requires a balance between the public benefit from the proposed expansion and the need to protect the livability and vitality of the surrounding neighborhoods. A key component of finding the appropriate balance relates to the public benefit and bed projections for the alternatives reviewed in the DEIS.

Children’s has proposed ten times greater than the number of beds that it will need in the next 20 years. The DEIS fails to provide sufficient information about bed need and the State Department of Health’s methodology for this determination. A recent, independent study prepared by Field Associates applying the Department of Health’s 12-step methodology in determining bed need should be analyzed and included in the EIS.

An oversupply of beds puts an economic burden on the public. Children’s is proposing to add 350 beds. With this oversupply, patients, health insurance purchasers, carriers and taxpayers will pay the price and the cost of health care will ultimately rise. In addressing the public benefit issue using the methodology of the Department of Health, the EIS should analyze oversupply and the potential impact on increased health care costs. Similarly, the EIS should study the impact on the financial and program viability of other hospitals due to the unnecessary duplication of hospital beds at Children’s.

Inpatient demand at Children’s has declined since adding beds in 2004. The DEIS fails to cite this information provided by Children’s to the Department of Health in its quarterly reports. Instead, the DEIS cites information about inpatient demand prepared by a pediatric hospital organization of which Children’s is a member. To ensure objective, reliable information about health care and population trends upon which decisions can be made, the EIS should use the same data sources that the Department of Health uses, rather than simply relying upon information provided by Children’s or its member organizations.

To ensure an appropriate level of expansion, Children’s should apply for its certificate of need now. A certificate of need at this time would provide a road map for an appropriate level of expansion. The DEIS incorrectly states that Children’s cannot apply for its certificate until the major institution master plan is approved. State regulations provide that the Department of Health may commit to issuing a certificate of need subject to timely receipt of an environmental determination. There are examples on the State’s website. In one case, a 175-bed hospital received a commitment to receive its certificate prior to even site selection, zoning and other approvals. Children’s has recently unveiled its Train Addition expansion that will be completed under its current approved master plan. This project will add 20-25 beds and yet Children’s has failed to file for its certificate of need authorizing the project to move forward.

Height, Bulk and Scale

(Statement by Leslie Wright)

All of the proposed alternatives (other than the no-build alternative) call for approximately 1.5 million square feet of new development and building heights of 160 feet. This expansion is more than one and one half times the size of the current hospital. There is no conceivable way to mitigate the significant height, bulk and scale impacts. The DEIS fails to include sufficient analysis of these issues and impacts. The final EIS should reduce the square footage and building height of the alternatives. Children’s should be held to the same standards of other similarly situated major institutions.

No other institution has proposed an expansion in a low density, single-family zone of the magnitude proposed by Children’s. Children’s last master plan called for an additional 250,000 square feet. This time they are asking for 1.5 million square feet. To minimize the impacts, the DEIS alternatives should be revised to reduce the proposed square footage expansion.

Children’s Floor Area Ratio (FAR) should be consistent with other major institutions located outside urban villages. This measurement of density is the ratio of building square footage divided by the square footage of the lot. Children’s current approved FAR is .9. The DEIS alternatives double or more than double the hospital’s existing density with FARs that range from about 1.82 to 2.35. Keeping the FAR at .9 with the proposed expansion would allow considerable expansion while retaining the current open space standards. Recently adopted master plans in low density areas have approved a FAR of .3 for South Seattle Community College and .9 for Seattle Pacific University. The final EIS should revise the current alternatives to keep the FAR at .9.

The maximum Major Institution Overlay (MIO) building height should be reduced to 90 or 105 feet. The maximum MIO height approved by the City Council for an institution outside of an urban village (areas targeted to receive growth and increased density) is 105 feet. Six of Seattle’s major institutions are located in a context similar to Laurelhurst. While 105 feet is the maximum allowed by the City Council for these institutions, one (Seattle University) has a maximum MIO height of 50 feet, because that is the height consistent with the surrounding community. The final EIS should revise the alternatives to reduce maximum building heights to 90 or 105 feet for buildings on the main campus to ensure compatibility with the surrounding community.

There is substantial additional development capacity under existing institutional heights, or potentially with modest increases to some of these heights. Even with completion of the remaining Train addition, Children’s can meet its needs with additional capacity south and north of Penny Drive under the current 50 and 70-foot height limit or with an increased 90 foot height limit. Structures at grade or on top of underground parking garages, terraced to the site’s sloping topography could mitigate the height, bulk and scale through setbacks and other measures. The final EIS should analyze these possibilities and modify existing alternatives.

The L-3 zoning designation (30 feet) for the Hartmann site should be retained. Both height increases and expansion of the major institution boundaries are proposed for this site in two of the proposed alternatives. The DEIS fails to adequately analyze the impact of increasing the zoning height to 105 feet in Alternative 3 and 65 feet in Alternative 7 and converting this site to institutional uses. The DEIS does not address the City’s rezone criteria in including the proposed height increases. With the exception of the condominium complex to the south of the Hartmann site, which is designated as a nonconforming use, the remainder of Sand Point Way is zoned with 30 and 40 foot heights. The higher proposed heights would be grossly out-of-scale with the rest of the retail area and dramatically taller than other surrounding residential properties to the north and west. Under existing zoning with no expansion of the major institution boundaries, the property can be redeveloped with moderate-income housing to replace the housing that would be demolished should the Early Laurelon alternative be the preferred option.

Children’s should be required to adhere to the City’s Land Use Code and Comp Plan. The proposed building heights are inconsistent with the Land Use Code and the Comprehensive Plan goals and policies that emphasize the need to preserve single family scale and character. The final EIS should include an analysis of how each alternative complies with the Code and the Comp Plan. This would only be possible with reduced square footage and building heights.

Expansion of Major Institution Boundaries

(Statement by Mark Trumbauer)

Children’s has proposed expanding its major institution boundaries to add considerable acreage to include the Hartmann site across Sand Point Way and the 136-unit Laurelon garden condominium complex. The DEIS includes alternatives that would allow this expansion of boundaries with no attention to the mandates of the Major Institutions Code, the Land Use Code or the City’s Comprehensive Plan.

Children’s plan to expand its institutional boundaries will be destructive to the land use character and function of the residential community that lies west of the campus and to the commercial district. The DEIS fails to adequately address the impacts.

The City’s Comprehensive Plan, Major Institutions Code and rezone criteria strongly discourage major institution boundary expansion. The restrictions and prohibitions on boundary expansion are intended to prevent institutional sprawl, isolation of private properties and uses and elimination of housing and independent neighborhood businesses and services. These impacts can undermine or destroy the viability and livability of the affected community. The rezone criteria for boundary expansion specifically require that boundaries provide for contiguous areas that are as compact as possible within constraints of existing development and property ownership. The final EIS should analyze these issues and the Comp Plan and Code provisions. The institutional boundary should not be expanded to the Hartmann property in any alternative.

Leap-frogging over Sand Point Way to annex the Hartmann property will precipitate additional westward expansion of Children’s facility and uses serving the institution. Properties surrounding Children’s are perpetually affected by the institution’s increasing dominance in the area. Residents and businesses balk at making capital improvements to their properties when the long-term fate of the immediate area is uncertain. While the DEIS points out that boundary expansion may lead to more retail and customer service businesses to serve the institution’s increased staff, patients and visitors, it is more likely that the nearby business and residential areas will take on the character of a “company town” with properties increasingly owned or controlled by Children’s. It is likely that the Springbrook Building and other properties along Sand Point Way will eventually become a part of Children’s expanding campus. The DEIS fails to acknowledge and address the detrimental impacts on the vitality, livability, diversity and viability of the surrounding areas.

Instead of expanding Children’s boundaries to include the Hartmann site, the final EIS should explore other options for this property. Substantial moderate-income housing could be developed on this site under the existing L3 zoning. Options to expand patient housing could be explored. The final EIS should revise the alternatives to address options consistent with the Comp Plan, the Major Institutions Code and existing zoning.

Children’s proposed boundary expansion contributes to institutional sprawl outside of a transportation hub. Residential, commercial and other property owned by Children’s in the vicinity continues to sprawl around the perimeter of the campus. This is contrary to the City’s urban village growth strategy and will ultimately lead to pressure to continue to expand institutional boundaries and increase density, even in single-family residential areas. The final EIS should analyze these issues.

Expansion of Children’s boundaries to include Laurelon Terrace for institutional uses will result in the loss of a considerable component of moderate income housing in the area. The 136-unit garden condominium complex cannot be replaced. The Lowrise 3 zone should be retained and the property redeveloped with new multi-family residences. Alternatives 3 and 6 would permit this redevelopment within existing zoning.

Expansion of Children’s boundaries to include Laurelon Terrace should only be considered within strict parameters. The maximum height should be no more than 105 feet and there should be substantial terracing of heights stepping down towards street boundaries. To ensure a transition to the surrounding community, 75 foot setbacks should be mandated along all streets with new construction.

Housing

(Statement by Carey Lassen)

The Seattle Municipal Code prohibits expansion of major institution boundaries where “they would result in the demolition of structures with residential use unless comparable replacement is proposed to maintain the housing stock of the city.”

Should Laurelon Terrace be demolished for institutional uses, comparable moderate income housing should be provided. Children’s has indicated that it plans to contribute to the development of 52 units of low income housing at Warren G. Magnuson Park. Low income housing is not comparable to the loss of much needed affordable, moderate income housing. The DEIS incorrectly states that it is up to the City Council to determine if this partial replacement housing is “comparable.” The language of the Code is clear—comparable means comparable. Low income housing is not comparable to moderate income housing. As was stated by the City Council in the approval of the 2000 Harborview master plan, the institution must replace units with others of the same sizes and affordability levels at the time of the master plan approval.

Replacement comparable housing should be provided in the vicinity of the demolished housing. Low income housing at Magnuson Park is not in the vicinity of the Laurelon housing that would be demolished. The loss of 21 percent of moderate income housing in the Laurelhurst area is considerable. During the Harborview master planning process, the Citizens Advisory Committee (CAC) recommended that all replacement housing be located within one quarter of a mile of the major institution boundary. Due to the highly developed character of that area, the City Council provided a modest extension of the vicinity for replacement housing. The Children’s CAC should provide its recommendations for the appropriate vicinity of replacement housing. The final EIS should mandate appropriate vicinity for locating replacement housing.

Replacement comparable housing should be provided at the Hartmann property under existing zoning. The Hartmann site should be redeveloped as multi-family housing that is comparable to the Laurelon Terrace complex—with similar townhouse unit type, site design and density. The condominiums should be available through the market in non-institutional ownership. The Lowrise 3 zoning (30 feet) would allow one unit per 800 square feet of lot area. A considerable amount of replacement housing could be provided on this site. The final EIS should analyze and include this option.

Plans for replacement housing should be in place prior to any demolition of Laurelon Terrace. It is not sufficient as stated in the DEIS that Children’s has committed to working in partnership with public agencies, nonprofit organizations, housing developers and others to maximize opportunities to leverage more affordable housing in northeast Seattle. Nor, is it sufficient for Children’s to merely state that it will meet its replacement housing responsibilities by contributing to development of 136 units. No demolition of Laurelon should occur without Children’s commitment to replace the 136 units and to do so prior to demolition. This requirement was included in the Harborview master plan and should be incorporated in the final EIS.

Transportation

(Statement by Colleen McAleer)

The traffic and transportation impacts associated with the proposed “build” alternatives are considerable. The only way to mitigate these impacts to protect the livability and vitality of the surrounding communities as required by the Major Institutions Code is to reduce the magnitude of expansion.

An increase of 8,400 vehicle trips per day to the Children’s campus will result in major congestion along Sand Point Way and in the vicinity that cannot be mitigated. The level of service (LOS) at five locations under Alternatives 3 and 7 would be at “E” or “F.” These locations include: Five Corners, Montlake Boulevard and NE 45^th, Montlake Boulevard and the SR 520 eastbound ramps, 40^th Avenue NE and NE 55^th Street (by the Metropolitan Market) and 40^th Avenue NE and NE 65^th. Alternative 1 includes one additional failing location—25^th Avenue NE and University Village. The failing Level of Service means longer waiting times at intersections and increased pedestrian and bicycle safety issues. As a peninsula, Laurelhurst is particularly impacted. In addition to resolving questions about the validity of the projected traffic volumes, the final EIS should revise the “build” alternatives to acceptable levels of expansion to minimize traffic impacts. The DEIS correctly recognizes that the potential for traffic safety issues increases proportionately with increases in traffic volumes, but likely underestimates the increased volume of traffic.

Hospital access on NE 50^th and NE 45^th Streets should be eliminated. Alternatives 3 and 6 would allow in and out access on NE 50^th and shuttle access on NE 45^th Street, in addition to access on Sand Point Way. It is inappropriate to direct high volumes of traffic onto residential streets. NE 50^th is a narrow roadway with areas of impaired sight distance that cannot handle increased traffic and speeds. Shuttle deliveries should remain at the Giraffe entrance. Creating a shuttle entrance on NE 45^th would likely result in the entrance later opening to patient, staff and visitor access.

Adequate parking must be provided. The DEIS states that 3,100 parking stalls will be provided with an enhanced TMP, but recognizes a need for 3,600 stalls. The growth factors for facilities and beds does not correspond with the data provided on parking or trip generation. The final EIS should correct this.

The DEIS appears to grossly underestimate the number of vehicle trips per day. The DEIS estimates 8,400 vehicle trips per day, however, using the standard Institute of Transportation Engineers formula, the number of trips per day would be 42,000. The final EIS should provide trip generation data, employ standardized calculations regarding vehicle trips and provide sufficient parking.

Because the Children’s Transportation Management Program calls for reducing or eliminating free parking, overflow parking in the neighborhood is to be expected. While Children’s has effectively controlled staff parking in the neighborhood, there is no mechanism to do this for patients and visitors. As mitigation, Children’s should be required to pay for implementation of Residential Parking Zones, as well as for the annual permits and enforcement.

Children’s plans to double the number of its shuttles to reduce vehicle trips. The problem is that the current shuttles are frequently empty or receive a small volume of riders. They contribute to traffic congestion along Sand Point Way and in the area and pose threats to pedestrian and vehicle safety. Doubling the number of shuttles with no measurement of the effectiveness of the current shuttles makes no sense. The final EIS should be revised to include actual data of shuttle usage and effectiveness, and actual data on both shuttle trips and other vehicle trips in and out of the campus.